Personal Data Protection Policy
Our commitment to Your Privacy
This Personal Data Protection Policy documents our adherence to industry standards for the protection of your Personal Data. Please take a moment to read this Personal Data Protection Policy so that you know and understand the purposes for which we collect, use and disclose your Personal Data. This policy supplements but does not supersede nor replace any consents you may have previously provided to us in respect of your Personal Data, and your consents herein are additional to any rights which any of us may have at law to collect, use and/or disclose your Personal Data.
References to “we,” “our,” or “us” herein refer to Sunshine Kids Care Centre, its subsidiaries, and affiliates, business partners, associates, agents and/or employees.
Scope of the Personal Data Protection Policy
This policy covers our treatment of Personal Data that is collected in the course of your interaction with us and while you are on our site. For the purposes of this policy, “Personal Data” refers to any data, whether true or not, about an individual who can be identified (i) from that data, or (ii) from that data and other information to which we have or are likely to have access, including data in our records as may be updated from time to time.
Examples of Personal Data (depending on the nature of your interaction with us) include unique identifiers (eg. NRIC or FIN number, passport number) as well as any set of data (eg. telephone number(s), mailing address, photo or video images) which when taken together would be able to identify the individual. Such information may be provided to us by you in any forms submitted to us or via other forms of interaction with us.
This policy does not apply to the practices of companies not owned or controlled by us or to people whom we do not employ or manage, nor does it address non-personally identifiable information. This policy does not apply to information collected at a website of an affiliated company or business line that may be linked to this website; in those cases, the privacy policy provided at that web site will apply.
Collection of Personal Data
Generally, we may collect Personal Data from you or your child/ward in the following ways:
(i) When you arrange for a visit to our school/centre;
(ii) When you submit an application for your child/ward to be enrolled with the school/centre or submit forms for school/centre activities;
(iii) When you interact with our staff (whether via telephone calls, letters, emails or during face-to-face meetings);
(iv) When you are contacted by, and respond to, our staff;
(v) In the course of providing educational services to your child/ward;
(vi) when your or your child’s/ward’s images are captured by us via CCTV cameras while you are within our premises, or via photographs or videos taken by us or our representatives when you or your child/ward attend events hosted by us or any third party organiser we appoint;
(vii) when you request that we contact you, be included in an email or other mailing list; or when you respond to our request for additional Personal Data, our promotions and other initiatives;
(viii) When you submit your Personal Data to us for any other reasons.
You should ensure that all Personal Data submitted to us is complete, accurate, true and up-to-date. We also collect anonymous, aggregate information from all visitors to our site. However, this information is never linked to any personally identifiable information and is used in the aggregate to generate statistical reports about the use of our site.
Use, Disclosure, and Process of Personal Data
We may use, disclose or process Personal Data about you collected before 2 July 2014 for the purposes for which the Personal Data was collected unless consent for such use is withdrawn in accordance with applicable law or if you have otherwise indicated to us, whether before, on or after 2 July 2014, that you do not consent to the use of such Personal Data.
Purposes of Collection, Use, and Disclosure
Depending on your relationship with us, the Personal Data which we collect from you or your child/ward may be collected, use and/or disclosed for the following purposes:
(i) for maintaining student records;
(ii) for school/centre communications;
(iii) for audit, administration and emergency purposes;
(iv) for emergency contact;
(v) for school/centre or extra-curricular activity registration;
(vi) responding to requests from child care regulators, medical providers, payment processors and financial institutions;
(vii) evaluating suitability for admission or employment;
(viii) carrying out due diligence or other screening activities (including background checks) in accordance with legal or regulatory obligations or risk management procedures that may be required by law or put in place by us, including the obtaining of references and/or other information from prior educational institutions and employers;
(ix) investigating possible fraud, misconduct, unlawful action or omission, and utilizing electronic access and video systems to maintain security of persons or property, control access and investigate suspicious or inappropriate activities including but not limited to possible violation of any terms and conditions or policies posted on our website;
(x) responding to requests for information from government or public agencies, ministries, statutory boards or other similar authorities or non-government agencies authorized to carry out specific Government services or duties;
(xi) supporting our functions including, but not restricted to, the teaching and personal and professional development of students and administration of our schools/centres;
(xii) processing, administering and conferring awards of prizes and student or graduation status, and publication or releasing of information on the same;
(xiii) processing applications and enrolment activities related to health, life and travel insurance and service provision as well as school-related cards, and administering matters related to use of those services;
(xiv) taking photographs and/or videos (whether by our stuff or third party photographers and/or videographers) during events organized by us;
(xv) for us to provide you with information about our services and our affiliate schools/centres;
(xvi) any other purposes which we may inform you of in writing from time to time, but for which we will seek your separate consent.
If you have provided us your Singapore telephone number(s) and/or email address and have indicated that you
consent to receiving marketing or promotional information via your Singapore telephone number(s) and/or email
address, then from time to time, we may contact you using such Singapore telephone number(s) (including via voice
calls, text, fax or other means) and/or email address with information about our services and schools/centres.
Disclosure and Transfer to Third Parties
We will take reasonable steps to protect your or your child’s/ward’s Personal Data against unauthorized disclosure.
We may disclose your or your child’s/ward’s Personal Data to third parties without first obtaining your consent in
certain situations, for example:
(i) where disclosure is required or permitted by applicable law and/or regulations;
(ii) where necessary, to our third party service providers, payment processors, agents, regulatory bodies and
auditors in the ordinary course of our business and subject to any restrictions imposed by the applicable law and/or
regulations;
(iii) where you have authorised us to disclose your Personal Data another party.
The instances listed above are not exhaustive. In all other instances of disclosure of your Personal Data to third
parties with your express consent, we will provide for adequate forms of protection over such Personal Data, and
confidentiality and security in the handling and administration of your Personal Data by such third parties in
compliance with applicable law.
Personal Data of Children
We have designed our site for parents and adults, not for children. For that reason, we do not knowingly collect
Personal Data from children who may visit our site, and we do not want to include any such information in our
customer databases. We recommend that parents monitor their children’s use of the Internet.
Management and Care of Personal Data
Wherever your Personal Data is in our possession or under our control, we will take reasonable and appropriate
steps to protect your Personal Data from unauthorized access, collection, use, disclosure, copying, modification,
disposal or similar risks. We shall also take reasonable and appropriate measures to keep your Personal Data
accurate, complete and updated.
We also make an effort to protect your information offline. However, given the nature of the Internet and the fact that
network security measures are not infallible, we cannot assume responsibility for any unauthorized use of your
Personal Data by third parties which are wholly attributable to factors beyond our control.